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81 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    so. Despite the fact that Mrs. Colombell received no tax benefit whatsoever from her “participation” in Inova’s retirement plan, the Court is not free to rewrite the law. See, e.g., Hildebrand v. Commissioner , 683 F.2d 57, 59 (3d Cir. 1982), affg. T.C. Memo. 1980-532; Johnson v. Commissioner , 661 F.2d 53, 54-55 (5th …
  2. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    l section references are to the Internal Revenue Code in effect for 1991, the taxable year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2 Sec. 4980A imposes a 15-percent excise tax on excess distributions from qualified retirement plans. This tax is included within ch. 43 of the I…
  3. T.C. Summary Opinion 2018-15 — Gary K. Sherman & Gwendolyn L. Sherman a.k.a. Gwen L. Sherman v. Commissioner
    IRCCourt RulingsApr 2, 2018
    …yer worked or works for the payor".7 6Bot v. Commissioner, 118 T.C. 138, 145 (2002), afCd, 353 F.3d 595 (8th Cir. 2003). 7Jackson v. Commissioner, 108 T.C. at 135 (quoting Milligan v. (continued...) - 10 - In Peterson we found that "[t]he Mary Kay distributions were 'tied to' the quantity and quality of Mrs. Peterson's…
  4. 89 T.C. 287; 89 T.C. No. 25 — Larotonda v. Commissioner
    IRCCourt RulingsAug 13, 1987related by meaning
    alty was designed to cover the situation involved herein. Because of such doubt, we think it judicious to resolve this issue in favor of the taxpayer. Finally, we must decide whether additions to tax pursuant to section 6653(a)(1) and (a)(2) should be imposed. Section 6653(a)(1) provides for an addition to tax of 5 per…
  5. 102 T.C. 695; 102 T.C. No. 31 — Fazi v. Commissioner
    IRCCourt RulingsMay 19, 1994related by meaning
    and offered the administrative record from the declaratory judgment case, which has been received as part of the record in this deficiency proceeding. Section references are to the Internal Revenue Code in effect for the periods under consideration. Rule references are to this Court’s Rules of Practice and Procedure. T…
  6. 54 T.C. 953 — Estate of Benjamin v. Commissioner
    IRCCourt RulingsMay 11, 1970related by meaning
    n after October 31, 1951, from 65 to 55⅛ The trust instrument as amended on or prior to November 15,1955, further provides: SECTION III Contributions: A. As and when a participant shall elect to continue as a participant, or as and when an eligible employee who is not a participant shall elect to become a participant, …
  7. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    IRCCourt RulingsJun 24, 2003related by meaning
    tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …
  8. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    1, 933 (2d Cir. 1932), rev'g 22 B.T.A. 1171 (1931)), aKg T.C. Memo. 1982-209. With that admonition in mind, we resolve these cases on their particular facts, applying the text of the relevant Code provisions. For the reasons discussed below, we reject petitioners' broadest argument--that the substance doctrines have no…
  9. 70 T.C. 158 — Ma-Tran Corp. v. Commissioner
    IRCCourt RulingsMay 4, 1978
    … 9,100.00 1970 . 14,325.00 8,925.00 1971 . 32,967.03 24,692.04 1972 . 36,167.03 24,182.97 1973 . 32,595.30 24,795.30 It paid dividends totaling $520 to minority shareholders in both its fiscal years 1972 and 1973. Ma-Tran’s corporate income tax returns for fiscal years 1972 and 1973 were prepared by William Gryder, a c…
  10. 73 T.C. 1142 — Home Interiors & Gifts, Inc. v. Commissioner
    IRCCourt RulingsMar 24, 1980
    …016.12 85,640.68 107,788 Total 398,246.00 651,577.32 942,047.46 1,185,666 989,516 Profit-sharing 58,595.30 96,206.43 139,191.71 175,510 146,153 Total 456,841.30 747,783.75 1,081,239.17 1,361,176 1,135,749 Andrew J. Homer Salary $12,000.00 $12,000.00 $12,000.00 $12,000 $12,000 Commission 44,519.40 73,769.90 106,750.85 1…
  11. 106 T.C. No. 3 — James H. & Josephine A. Swanson v. Commissioner
    IRCCourt RulingsFeb 14, 1996related by meaning
    er 8,250-8,250 IRA-1st Fla. 2,500 2,500 - IRA-1st Fla. 5,000 5,000 - 401-K Plan 45,000 45,000 - Condo 185,000-185,000 Industrial Bldg. 107,500-107,500 Industrial Bldg. 260,000-260,000 Industrial Vacant 65,000 65,000 - Stock - HSSTC 59,200 59,200 - Prestige 23,500-23,500 Breck 25,000 25,000 - West Coast 25,000 25,000 - …
  12. 90 T.C. 862; 90 T.C. No. 58 — New York State Teamsters Conference Pension & Retirement Fund v. Commissioner
    IRCCourt RulingsMay 9, 1988
    …d Retirement Fund v. Commissioner, T.C. Memo. 1982-594, and Wenzel v. Commissioner, T.C. Memo. 1982-595, affd. on consolidated appeal Wenzel v. Commissioner, 707 F.2d 694 (2d Cir. 1983). Loftus v. Commissioner, 90 T.C. 845 (1988), concerned the request for a determination only as it related to the Brewery Workers Fund.
  13. T.C. Memo. 2004-111 — James J. & Marilyn R. Milner v. Commissioner
    IRCCourt RulingsMay 4, 2004related by meaning
    ners are liable for the 10percent additional tax on the $55,555 early distribution that petitioner received from the plan. 2 To reflect the foregoing, Decision will be entered for respondent .
  14. T.C. Summary Opinion 2001-158 — Majid Naemi v. Commissioner
    IRCCourt RulingsSep 26, 2001related by meaning
    effect, rewrite the statute to achieve what seems to be a more equitable result. See Eanes v. Commissioner , supra at 171. “Whether and to what - 6 - extent deductions shall be allowed depends upon legislative grace; and only as there is clear provision therefor can any particular deduction be allowed.” New Colonial Ic…
  15. 81 T.C. 91; 81 T.C. No. 8 — Van Kalker v. Commissioner
    IRCCourt RulingsAug 4, 1983related by meaning
    ven if the income was attributable primarily to personal services. If capital is material, as it is here, the statutory 30-percent limitation applies. As explained in note 7, supra, Congress, in the Revenue Act of 1978, amended section 1348, effective for taxable years beginning after December 31,1978, to remove this m…
  16. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    t higher contributions, section 4973(a) imposes for each taxable year an excise tax of 6% for excess coritributions, computed on the lesser of (1) the amount of the exceså contribution, and (2) the value of the account as of the end of the taxable year. The tax appliës eách year until the excess contributions are elimi…
  17. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990
    …iency Sec. 6651(a)(1) Sec. 6651(a)(2) 12/31/80 $1,524 $383 $381 12/31/81 4,211 947 2,000 12/31/82 6,595 1,484 2,803 12/31/83 8,972 2,019 3,275 12/31/84 11,242 2,529 3,428 12/31/85 13,619 2,451 2,723 Respondent also determined a deficiency in second-tier tax under sec. 4975(b) of $286,911. Robert C. Slaton Docket No. 39…
  18. Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t)
    IRCNoticesJul 8, 2024related by meaning
    nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code. VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
  19. 85 T.C. 168; 85 T.C. No. 10 — Eanes v. Commissioner
    IRCCourt RulingsJul 30, 1985related by meaning
    the instant case, as the excess of the amount contributed to the IRA for the taxable year over the amount allowable as a deduction under section 219. Since petitioner is not entitled to a deduction under section 219 for his contribution for $1,500 to an IRA in 1981, the entire $1,500 represents an excess contribution …
  20. 87 FR 26806 — Use of Actuarial Tables in Valuing Annuities, Interests for Life or a Term of Years, and Remainder or Reversionary Interests
    IRCProposed Rules (FR)Proposed May 5, 2022
    …74.83 2 99,341.16 39 96,915.25 76 67,044.59 3 99,313.80 40 96,761.20 77 64,773.93 4 99,292.72 41 96,595.51 78 62,366.05 5 99,276.45 42 96,416.30 79 59,795.50 6 99,261.55 43 96,220.61 80 57,080.84 7 99,248.33 44 96,005.41 81 54,213.71 8 99,236.50 45 95,768.60 82 51,205.27 9 99,226.09 46 95,509.98 83 48,059.88 10 99,217.…